Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 17 of 21

Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 17 of 21 sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. 56. Defendants Epstein and Maxwell's sexual demands on Plaintiff continued while she was in New York or other geographic proximity to the Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. 57. In May, 2007, Plaintiff left the United States and did not return. 58. Defendants' representations and promises were all false and fraudulent. Their threats were considered by Plaintiff to be real and credible. All such representations, promises and threats were made solely for the purpose of coercing and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefittcd financially and received things of value as a result of their participating in their illegal enterprise. COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. tt 1595 59. Plaintiff adopts and real leges paragraphs I through 58 above. 17 EFTA00313660